In United States v. Dotterweich (1943) 320 U.S. 277, the Supreme Court addressed whether the president/general manager of a corporation, as well as the corporation itself, could be liable under the Federal Food, Drug, and Cosmetic Act (21 U.S.C. 301 et seq.; the Act), which imposed criminal liability on "'any person'" shipping adulterated or misbranded drugs. (Dotterweich, supra, 320 U.S. at p. 278.) The federal appellate court had reversed Dotterweich's conviction on the ground that only the company was the "'person'" subject to prosecution unless the company "was a counterfeit corporation serving as a screen for Dotterweich." (Dotterweich, at p. 279.) The Supreme Court disagreed and held that the offense is committed by all who have "a responsible share in the furtherance of the transaction which the statute outlaws." (Dotterweich, at p. 284.) Central to the court's holding was that the Act was public welfare legislation and the statute imposed strict liability. (Dotterweich, at pp. 280-281.) Specifically, the Act extended the range of Congress's "control over illicit and noxious articles and stiffened the penalties for disobedience," thus "touching phases of the lives and health of people which, in the circumstances of modern industrialism, are largely beyond self-protection." (Dotterweich, at p. 280.) And the statute allowed for criminal conviction without proof of "awareness of some wrongdoing," thus "putting the burden of acting at hazard upon a person otherwise innocent but standing in responsible relation to a public danger." (Dotterweich, at p. 281.) The Supreme Court further explained why Dotterweich, and not just the corporation, was liable. "The statute makes 'any person' who violates it guilty of a 'misdemeanor.' It specifically defines 'person' to include 'corporation.' But the only way in which a corporation can act is through the individuals who act on its behalf. ... If, then, Dotterweich is not subject to the Act, it must be solely on the ground that individuals are immune when the 'person' who violates the statute is a corporation, although from the point of view of action the individuals are the corporation." (Dotterweich, supra, 320 U.S. at p. 281.) The court examined the evolution of the establishment of criminal liability for a corporation, noting that it had "taken time to establish criminal liability also for a corporation and not merely for its agents" and were the court to hold the Act freed all individuals, except when proprietors, from culpability, such a holding would "defeat the very object of the new Act," which was "designed to enlarge and stiffen the penal net and not to narrow and loosen it." (Dotterweich, at pp. 281-282 88 L.Ed. at p. 52.)